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Winn-Dixie Stores, Inc. v. Commissioner

United States Court of Appeals for the Eleventh Circuit
254 F.3d 1313 (11th Cir. 2001)


Facts

Winn-Dixie Stores, Inc. (Winn-Dixie) (plaintiff) instituted a company-owned life insurance (COLI) program that was intended to serve as a tax shelter. Under the COLI program, Winn-Dixie purchased whole life-insurance policies on almost all of its thousands of employees, naming itself as the sole beneficiary. Winn-Dixie borrowed substantial funds against the whole life policies and claimed deductions for the interest payments on these loans on its federal tax returns. The net result of the COLI program on Winn-Dixie’s federal tax liability was to yield interest deductions projected to be in the billions of dollars over a 60-year period. The federal tax commissioner (commissioner) (defendant) disallowed Winn-Dixie’s interest deductions. Winn-Dixie petitioned the United States Tax Court for a redetermination. The tax court entered judgment in favor of the commissioner, holding that Winn-Dixie’s COLI program was a sham transaction because it could not generate a pre-tax profit. Winn-Dixie appealed to the United States Court of Appeals for the Eleventh Circuit.

Rule of Law

Issue

Holding and Reasoning (Per curiam)

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